Evidence that they had no documents to prove huge cash withdrawals were used for legal fees was "inexplicable", he said.

Mr Murphy is making submissions for the bank in an application before the High Court concerning disclosure by members of the Quinn family about alleged asset-stripping of the International Property Group of companies.

Members of the Quinn family were cross-examined for five days in January about their disclosure of assets and bank accounts.

Mr Murphy said evidence was given that huge sums of cash withdrawn in Ireland were used for legal fees, yet no bills or receipts could be accessed.

He said the "shutters had come down" with regard to the money trail and a confusing picture had emerged about what the money was used for.

Mr Murphy said there were a number of areas of concern about the level of disclosure by the Quinns and further court orders may be necessary.

Orders could be made directing Aoife Quinn to have a laptop forensically examined to retrieve deleted emails.

He said the "policy of deletion" outlined by the Quinns illustrated that full disclosure had not been made.

A number of striking features had emerged in evidence, he said, including the fact that none of the Quinns appeared to have copies of employment contracts or evidence of job descriptions, despite receiving large sums from Russian companies.

Salaries received by some of the Quinns from IPG companies were significantly larger than the Russian employees, often tenfold, illustrating that Seán Quinn Jnr played a major managerial and controlling role and not one of middle management as he had purported, he said.

There had been a lack of disclosure about the role some of the Quinns played in IPG companies, Mr Murphy said.

Documents existed that would show a level of control and leadership by Mr Quinn Jnr, Aoife Quinn and Stephen Kelly, he said.

IBRC has alleged widespread asset-stripping of Quinn companies.

The Quinns deny full disclosure has not been made.

Counsel for the Quinns, Martin Hayden SC, said the court would have to decide what exactly the order for disclosure was.

He said they were not seeking to avoid court orders or to be technical to avoid an obligation.

However, the process of disclosure differed from discovery, he said.

Disclosure orders did not go beyond the requirement of disclosing documents in the possession of a defendant, he said.

Discovery was a much broader concept, while disclosure was narrow.

The current orders being sought by the bank amounted to it seeking an "evidentiary trail to support its argument in the main action".

Mr Hayden said it could not be a game of trial by ambush.

IBRC's application for further disclosure orders was entirely artificial in relation to the Quinn IPG groups as the bank had already appointed a receiver over those companies and would already have the information.

He said bank statements for accounts in Ocean Bank in Russia had been furnished.